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Krishan v. State of Haryana

Criminal Appeal · Neutral citation not assigned (Criminal Appeal No. 1342 of 2012)Decided 16 May 2014
Criminal Appeal No. 1342 of 2012
Justice Dipak Misra · Justice N.V. Ramana

Background

A woman reported being forcibly taken into a field and raped while carrying food to her parents. Krishan was convicted of rape and criminal intimidation, receiving a seven-year rape sentence. He argued that her lack of external injuries, her return home before reporting and an alleged prior dispute showed a fabricated accusation.

Decision Breakdown

The Court dismissed the appeal and upheld the convictions and sentences. The woman's account was supported by medical findings, the laboratory report and injuries on the accused consistent with the struggle she described. Absence of injuries on her body did not rule out rape, and going home before approaching police was not inherently suspicious. The false-implication theory lacked corroborating evidence. His bail was cancelled and immediate custody directed to serve the balance; the juvenility plea was not pressed before this Court.

Lesson Learnt

A sexual-assault complaint cannot be rejected merely because the survivor has no visible injuries or did not go directly to police. Courts assess the complete evidence rather than demand a single expected reaction or injury pattern.

Official source (sci.gov.in)View Judgment (PDF)

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